Introduction

United States v. Brock Beeman, decided by the Fourth Circuit on April 18, 2025, addresses three pivotal procedural questions arising from Beeman’s conviction for mailing threatening communications in violation of 18 U.S.C. § 876(c). After pleading guilty in an earlier prosecution for interstate threats, Beeman was indicted in Richmond for sending—or attempting to send—three letters to a prosecutor and an NCIS agent. On appeal, Beeman challenged:

• The admission of an uncharged (“fourth”) threatening letter.
• The empaneling of an anonymous jury.
• The denial of a mistrial after an allegedly improper prosecutorial remark in closing argument.

The Fourth Circuit affirmed the conviction in a published opinion by Judge Quattlebaum, joined by Judges King and Wynn. This commentary examines the Court’s treatment of intrinsic vs. extrinsic evidence under Federal Rule of Evidence 404(b), its anonymous‐jury framework, and the standards for closing‐argument objections and mistrials.

Summary of the Judgment

The Fourth Circuit reviewed all three challenges for abuse of discretion and concluded:

• Uncharged Letter: Properly admitted as res gestae (intrinsic) and, alternatively, under Rule 404(b) as evidence of motive, intent, identity, and absence of mistake.
• Anonymous Jury: Framework satisfied by Beeman’s history of threats, risk of juror intimidation, and reasonable safeguards (defense counsel received unredacted list; jurors instructed neutrally).
• Mistrial Motion: No prejudicial error from a single misstatement during closing argument, promptly corrected by both the court and counsel, with proper jury instructions reinforcing the objective‐threat standard.

Accordingly, the Fourth Circuit affirmed the district court’s judgment in all respects.

Analysis

1. Precedents Cited

• United States v. Delfino, 510 F.3d 468 (4th Cir. 2007): Standard for reviewing discretionary evidentiary rulings.
• Queen, 132 F.3d 991 (4th Cir. 1997): Introduction to Rule 404(b) and its purpose.
• Brizuela, 962 F.3d 784 (4th Cir. 2020): Distinction between intrinsic (res gestae) and extrinsic evidence, “complete the story” doctrine.
• Chin, 83 F.3d 83 (4th Cir. 1996): Intrinsic evidence in a murder‐for‐hire context during drug transactions.
• Kennedy, 32 F.3d 876 (4th Cir. 1994): Res gestae as contextual background for charged offenses.
• Dinkins, 691 F.3d 358 (4th Cir. 2012): Five‐factor test for empaneling anonymous juries.
• Ross, 33 F.3d 1507 (11th Cir. 1994): Influential Eleventh Circuit authority on jury anonymity factors.
• Lighty, 616 F.3d 321 (4th Cir. 2010) & Wilson, 624 F.3d 640 (4th Cir. 2010): Standards for evaluating prejudicial closing arguments and mistrial motions.

2. Legal Reasoning

The Court’s reasoning unfolds in three parts:

a. Intrinsic vs. Extrinsic Evidence under Rule 404(b)

• Intrinsic Evidence (Res Gestae): Acts “arising out of the same series of transactions” or “necessary to complete the story” of the charged crime need not trigger Rule 404(b). The uncharged letter shared:
  • Substantive threats of death and property destruction;
  • References to individuals and agencies from the Norfolk prosecution (motive/context);
  • Handwriting, typeface, and structural similarities (identity).
• Extrinsic Evidence under 404(b): Even if extrinsic, the letter was admissible to show motive, intent, identity, and absence of mistake. It satisfied:
  1. Relevance apart from character inference,
  2. Necessity to prove an element of § 876(c),
  3. Reliability (forensic handwriting match), and
  4. Probative value not substantially outweighed by unfair prejudice under Rule 403.

b. Anonymous Jury Procedure

Citing Dinkins and Ross, the Court confirmed that anonymity is permitted when:

1. Strong reasons exist to protect jurors from harm or interference, and
2. Reasonable safeguards preserve the defendant’s right to a fair trial.

The district court pointed to Beeman’s prior threats, risk of jury intimidation, significant penalties upon conviction, and potential media exposure. At the same time, defense counsel had full juror information for voir dire, and jurors were told anonymity served administrative discretion rather than a stigma.

c. Closing Argument & Mistrial Standard

When a prosecutor strayed from the “objective‐person” true‐threat test by inviting jurors to imagine their own feelings, the district court immediately intervened. Under our six‐factor test (Wilson/Lighty), the Court found:

• The remark was brief and isolated.
• It was corrected mid‐argument by counsel and the court.
• The jury received clear, correct legal instructions on the objective standard.
• Overwhelming evidence of Beeman’s guilt further minimized any effect.

No single factor or combination rendered a mistrial necessary absent prejudice.

3. Impact

United States v. Beeman provides practical guidance for trial courts and litigants:

• Res Gestae Clarity: Emphasizes a rigorous “nexus” test for intrinsic evidence—courts must ensure uncharged acts directly complete the story of the offense rather than serving as latent propensity evidence.
• 404(b) Practice: Reinforces the four‐part test (relevance, necessity, reliability, 403 balancing) for admitting extrinsic bad‐act evidence.
• Anonymous Jury Safeguards: Validates the Dinkins five‐factor inquiry and underscores the need for neutral jury instructions and defense access to juror data for voir dire.
• Closing Argument Jurisprudence: Confirms that isolated misstatements, promptly corrected and followed by curative instructions, rarely warrant a mistrial.

Complex Concepts Simplified

• Res Gestae: Latin for “things done”; evidence intrinsic to the charged crime because it completes the narrative of how the crime unfolded.
• Extrinsic Evidence (Rule 404(b)): Proof of “other wrongs or acts” not charged, admissible only for non‐character purposes (motive, intent, identity, etc.).
• Rule 403 Balancing: Even relevant evidence may be excluded if its danger of unfair prejudice substantially outweighs its probative value.
• Anonymous Jury Factors: A non-exhaustive list including the defendant’s history of threats, risk of juror harm, potential sentence, and media exposure.
• True Threat Standard: Under 18 U.S.C. § 876(c), the test is whether an objectively reasonable person would interpret the communication as a serious expression of intent to harm.
• Mistrial Standard: A drastic remedy requiring prejudice so severe that the trial cannot continue fairly; isolated and corrected errors seldom qualify.

Conclusion

United States v. Beeman reaffirms and refines critical trial‐level doctrines in federal criminal cases. It underscores the careful line between intrinsic evidence that “completes the story” of an offense and extrinsic bad acts subject to Rule 404(b). It also articulates the factors and safeguards necessary to justify an anonymous jury without compromising the presumption of innocence. Finally, the opinion demonstrates that isolated closing‐argument errors, promptly corrected and accompanied by curative instructions, do not undo otherwise sound convictions. Trial courts and practitioners will benefit from this structured roadmap when navigating evidentiary disputes, jury‐security measures, and prosecutorial boundaries in future threat‐related prosecutions.